Annette D. Goode-Parker - Page 3

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          assessed the correct amount.  The couple later separated, and Ms.           
          Goode-Parker has petitioned for innocent spouse relief.  Whether            
          we have jurisdiction turns on whether the Commissioner’s                    
          correction of the couple’s mistake was the assertion of a                   
               The marriage of Annette Goode-Parker and Marvin Parker began           
          in 1984.  Both were recent graduates of Howard University’s                 
          School of Law, and they started their life together by moving to            
          southern California.  In 1989, after working at a law firm and              
          then the Equal Employment Opportunity Commission, Ms. Goode-                
          Parker began her current career as a legal analyst in the                   
          California Department of Justice, specializing in consumer and              
          antitrust law.  Although she did not testify at length about her            
          husband’s employment, she did say that in 1992 or 1993 he left              
          his “regular job” to open a solo practice.                                  
               Her husband’s new practice was not immediately successful,             
          and the resulting financial stress began fracturing their                   
          marriage.  They soon found themselves battling the foreclosure of           
          their home.  They lost that fight and in 1995 moved into a                  

               1 Ms. Goode-Parker chose to have her case tried as a small             
          tax case under section 7463 of the Internal Revenue Code.                   
          (Section citations are all to that Code.)  That means that our              
          decision is not reviewable by any other court, nor may it be                
          treated as precedent in any other case.                                     

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